Sökning: "Coporate income tax"

Hittade 2 uppsatser innehållade orden Coporate income tax.

  1. 1. Head in the sand when trust income is in sight? Analysis of double taxation of trust income originating from dividends in light of Articles 49 and 63 TFEU.

    Magister-uppsats, Lunds universitet/Institutionen för handelsrätt

    Författare :Madara Olmane; [2023]
    Nyckelord :tax; Article 49 TFEU; Article 63 TFEU; trusts; fundamental freedoms; EU tax law; comparability; double taxation; trust income; dividends; freedom of establishment; free movement of capital; ECJ; flow-through dividends; coporate income tax; direct taxation; Law and Political Science;

    Sammanfattning : This thesis challenges the treatment of trust income received in a country with no trusts in its legal system in light of freedom of establishment and free movement of capital. Can provisions of a Member State that has decided not to have trusts in its legal system make the transfer of shares or even the establishment of a trust elsewhere less favourable? This question, as the starting point of this thesis, managed to open a Pandora’s box of additional aspects and questions to consider, where each deserves a thesis on its own. LÄS MER

  2. 2. Targeted interest deduction limitation rules post-Lexel

    Magister-uppsats, Lunds universitet/Institutionen för handelsrätt

    Författare :Alexander Tale; [2022]
    Nyckelord :Tax; EU; European Union; Interest; Targeted interest deduction rules; CIT; Coporate income tax; BEPS; OECD; Pillar Two; DEBRA; ATAD; IRD; Lexel; SIAT; Thin Cap; Deduction; Sweden; Court of Justice; Business law; Business and Economics; Law and Political Science;

    Sammanfattning : The need for targeted interest deduction rules is far from over. Most recently targeted interest deduction limitation rules have been presented in the proposal for a Directive implementing OECD Pillar Two in the EU, as well as in the proposal for a Directive on debt-equity bias reduction allowance. LÄS MER